Karin R. v. Kijakazi

Background

Karin R. challenged the Commissioner of Social Security’s denial of her applications for disability insurance benefits and supplemental security income. The administrative law judge found severe impairments including degenerative disc disease of the lumbar and cervical spine, chronic pain syndrome, and bilateral carpal tunnel syndrome after repair. The administrative law judge found Karin R.’s factitious disorder, depression, anxiety, and personality disorder non-severe, meaning they caused no more than minimal limitation in basic mental work activities.

The administrative law judge determined that Karin R. could perform light work, with limits on handling and fingering with each hand. Based on vocational-expert testimony, the administrative law judge found that she could perform her past work as a registered nurse supervisor or representative jobs such as cashier and mail-room clerk. The administrative law judge therefore found that she was not disabled.

The parties filed cross-motions for summary judgment. The court reviewed whether the administrative law judge’s decision was supported by substantial evidence, meaning relevant evidence that a reasonable person could accept as adequate.

Physical limitations and medical opinions

Karin R. argued that the administrative law judge improperly rejected limitations identified by her medical providers and improperly assessed her residual functional capacity, which is the most a person can do despite her limitations.

The court upheld the administrative law judge’s reasons for finding Dr. Hoxie’s opinion unpersuasive. Dr. Hoxie had offered very restrictive opinions about Karin R.’s ability to use her hands, including that she could never firmly grasp with her left hand and could not maintain the pace needed for competitive employment. The administrative law judge identified inconsistencies between that opinion and other evidence, including findings of normal or mildly reduced grip strength, intact movement and sensation, and Karin R.’s ability to perform activities involving her hands and upper extremities. The court concluded that these reasons reflected consideration of the opinion’s consistency with the record and were supported by substantial evidence.

The court reached a different conclusion regarding the state-agency medical consultants’ opinions. Those consultants had limited Karin R. to occasional handling and fingering with her right hand because of carpal and cubital tunnel syndromes. The administrative law judge found that limitation unpersuasive and concluded that Karin R. could handle and finger frequently with her right hand, relying on findings such as minimal swelling, no severe right-hand atrophy, and improvement in right-wrist pain after rehabilitation.

The court held that the administrative law judge improperly inferred the degree of workplace limitation from those medical notations without adequate medical support. The court explained that it was unclear what those findings meant for Karin R.’s ability to use her right hand at work without the administrative law judge making a medical judgment. The court therefore required reconsideration of the state-agency opinions and the related residual-functional-capacity assessment. Because of that conclusion, the court did not need to finally decide whether the administrative law judge separately erred regarding reaching limitations.

Mental limitations

Karin R. also argued that the administrative law judge failed to include mental limitations in the residual functional capacity. At the second step of the disability analysis, the administrative law judge found mild limitations in understanding, remembering, or applying information; interacting with others; and adapting or managing oneself, while finding no limitation in concentration, persistence, or pace.

The court explained that findings at the second step do not automatically become residual-functional-capacity limits. But the residual functional capacity must consider all medically determinable impairments, including impairments found non-severe. The court found that the administrative law judge provided little discussion of Karin R.’s mental impairments when determining her residual functional capacity and did not explain why no mental restrictions were included despite evidence supporting some limitations at the second step.

The court remanded for the administrative law judge to consider what limitations, if any, resulted from Karin R.’s non-severe mental impairments. The administrative law judge must also consider whether any updated limitations affect the questions posed to the vocational expert. The court declined to decide whether the administrative law judge must obtain additional medical evidence because it could not evaluate that issue without knowing the basis for the original decision not to include mental limitations.

Disposition

The court ordered that Karin R.’s motion for summary judgment be granted in part and denied in part. It ordered that the Commissioner’s motion for summary judgment be granted in part and denied in part. The court remanded the matter to the Commissioner under sentence four of 42 U.S.C. § 405(g) for further proceedings consistent with the opinion. The court did not award benefits or determine that Karin R. was disabled.